Flash EEPROM (Electrically Erasable and Programmable Memory) are a popular form of non-volatile memory. Flash EEPROM is operated by injecting electrons to a floating gate by tunneling into a floating gate through a tunneling oxide layer to cause a threshold voltage shift that is detected via current sensing. The magnitude of this threshold shift is related to the charge in the floating gate, the thickness of the controlling tunnel oxide, and other device parameters. To achieve non-volatility in Flash EEPROM's, the tunneling oxide thickness is maintained high enough (>7 nanometers (nm)) so as to prevent floating gate charge loss to the source and drain regions under normal read and retention conditions. The use of large oxide thicknesses, e.g. greater than 7 nm, necessitates the injection of charge into the floating gate at large voltages, e.g. 20 V, which results in MOSFET transistor hot-carrier degradation. As MOSFET transistors are being scaled down to achieve higher memory chip densities, the continuing use of large tunneling oxide thicknesses can result in poor memory transistor characteristics such as degraded read and write times and increased power consumption associated with chip standby as well as active modes.